Memorandum from Raglan Housing Association
Ltd (SPP 46)
QUESTIONS:
1. Consider the extent to which the Government
has, so far, delivered on the commitments it made in "Independence
and Opportunity: Our Strategy for Supporting People.
2. Consider the implications of the removal
of the ring fence, asking what needs to be done to ensure that
the successes of the programme so far are not lost, or services
cut, following the change.
3. Consider what opportunities this change
in the funding mechanism will offer for innovation and improvement
in the delivery of housing related support services.
SUMMARY OF
RESPONSE
The summary is being set out in a strength and
weaknesses format for ease of reference.
Strengths:
— Improved quality of service provision
standards.
— Improved by implication and fact, the
quality of life for service users.
— Has enabled users to be more informed.
— Has given local authorities the need
to make more informed decisions based on statistical need.
— Has given providers and users a point
of contact and advocate for service provision.
— Reduced number of inappropriate providers
yet offered help and opportunity for smaller providers.
— Improved variety of services and tackling
the need to help people in all tenure types.
— Encourage greater involvement of users
in services, both existing and potential users.
— Ring fenced funding has allowed growth
and sustainable service.
— Encouraged local authorities to increase
their risk taking to commission different ways of providing service.
— Greater regulation now evolving to improved
outcomes and flexibility of how outcomes obtained
— Integration of Supporting People Grant
into mainstream funding should allow further innovation if Health
rises to the challenge.
— Fits in with overall Government objectives
and appears to do "what it says on the tin"
Weaknesses:
— Over bureaucratic process.
— Lack of consistency of assessment standards
by differing Supporting People teams, both across local and regional
levels.
— Lack of response by way of inflationary
increases by Supporting People to match increased costs to providers.
— "Cost risk-shunting" across
to providers when only short term contracts given and capping
of user numbers within contracts.
— Implied objective of authorities to obtain
services by maximising numbers through a smaller number of providers,
justified on economies of scale which eliminates niche providers
of high quality services.
— A view by authorities that all services
should be similarly priced and does not account for the cost of
quality.
— Many authorities want providers to remodel
their services and/or buildings but will not give undertakings
to help finance them or give longer contracts to help pay for
the cost of building work.
— As Supporting People teams are dissolved
the expertise gained will be lost as their will be no focal point
of contact for users and providers alike.
— Many Supporting People teams are being
allowed to ignore the wishes of users, especially those in sheltered
housing projects.
— Removal of ring fence reduced the ability
of authorities to maintain support services as this finance will
be used for statutory services at the expense of non-statutory
ones.
— With move to Local Area Agreements there
are many (about a third) which do not use NIs 141 and 142 to measure
performance.
— Lack of integration with Health will
not change until Health is "forced" to engage meaningfully
in the process of service provision.
1. Consider the extent to which the Government
has, so far, delivered on the commitments it made in "Independence
and Opportunity: Our Strategy for Supporting People".
1.1 Improving Standards: The introduction of
standards that are regulated and enforced have raised standards
of services to users by providers, and as a provider of high quality
services this is welcomed. It is also welcomed that those rogue
providers have been substantially eliminated and providers who
were not providing higher quality services were offered the chance
to improve service delivery standards.
1.2 The down side of this is that in driving
up standards the cost of so doing has not been reflected in the
inflationary increases to providers, many such as this organisation
have seen a number of services go into deficit and are now considering
whether it can still maintain these services. This is further
compounded by recent changes of increased paternity and maternity
leave, increases to the minimum wage, employer national insurance,
revision payments and minimum leave entitlement.
1.3 Data Use: The strategic direction of local
authorities has improved based on the information that they have
obtained through research and consultation. What is disappointing
is that the quality strategic vision varies substantially across
the Supporting People authorities. Along with this is the substantial
investment in time by providers (not paid for) in completing returns
to Supporting People teams.
1.4 Keeping people that need services at the heart
of the programme
1.5 User Choice/Individual Budgets/Personalisation:
It is accepted that for many users this may be a very good improvement
to the way they can procure services and at the same time make
providers sharpen up the way they provide services.
1.6 The pilots for individual budgets have been
introduced based on pilots that were run over a short period of
time and the empirical evidence obtained is mixed, unclear and
from academic critique can not be used to substantiate change.
1.7 However, for some groups of vulnerable users
there needs to be careful consideration as to the financial benefits
they access. Those who can be unduly influenced by others may
use this freedom to spend as they want, in an inappropriate way.
People with drug and alcohol issues, those with Hearing Learning
Difficulties etc., may be over come by temptation unless safety
checks are put in place. This is not to be disparaging to those
who can benefit from having greater freedom to choose.
1.8 There is also a further consideration presented
by increased choice. That is, users want to retain services, say
of a resident or full time "warden" on site but this
option is unilaterally being taken away by Supporting People.
How does this validate the Government's claim to give service
users more choice?
1.9 Perversely, choice for users is likely to
reduce choice in actual terms as there is a real danger of providers
not being able to provide high quality services, or any services
at all, if income received from users is inconsistent and below
the level at which services are financially viable. Why should
providers financially underpin the local authorities and Government?
1.10 Effective communication with users: The
Quality Assessment Framework (QAF) has driven this standard forward.
However, as outlined in the previous paragraph, many Supporting
People teams do not communicate directly with users, taking decisions
believed to be on financial or ideological grounds rather than
the views of the users.
1.11 Challenging barriers to joined-up interventions:
The support for a continuum of seamless services is recognised
but this contradicts the issues of service procurement by Supporting
People Authorities and splitting off the "support" activities
from the "housing management" activities. Where both
are undertaken by one agency service continuity is easier but
where there is a different management agency and support provider
the continuity is more difficult. It is accepted there is a counter
argument that having an organisation that is both landlord and
support provider can be inappropriate but the advantages are seen
to easily outweigh the disadvantages.
1.12 Developing more integrated assessments:
This can only be welcomed but there appears little evidence nationally
that this is moving forward with any great speed. The introduction
of choice-based lettings that presumably should help in arriving
at common forms with common information and with common assessment
is surprisingly uncommon. Experience to date would show what appears
to be a distinct lack of motivation by Health to engage positively
on this. The past is going to haunt the future?
1.13 Meeting the needs of mobile groups and
individuals: The desire to help these difficult to access groups
is welcomed. However, the introduction of barriers to these groups
was introduced in 2003 and remains an issue at present. A foyer
in Poole has increasingly had to take young adults at great risk
of self harm because the facilities for people with emotional
problems are in Bournemouth (used previously as the regional resource).
Staff are having to undertake suicide watches on some residents
which is not, was, or should be, expected of this service.
1.14 Developing better communication and consultation
with users: It is agreed that a substantial amount of work has
been undertaken but with limited success and this varies across
Supporting People authorities. As Supporting People teams are
disbanded and subsumed into differing arms of authority services,
who will users and providers speak to in the future? It is believed
that with the development of Local Area Agreements and Area Based
Grants, the conduit of discussions will become more regionalised
with the users being marginalised, along with providers.
1.15 In the experience of providers and users,
some Supporting people authorities have failed to maintain regular
and informative meetings whilst others have worked very hard to
keep communication lines open. There is thus a large disparity
between the effectiveness of authorities.
1.16 Helping service users to make the right
choices: The increase in user choice can only be welcomed, but
not at the expense of services that already exist, which are valued
by these users and would disappear if income to maintain the service
is reduced. The issue of "brokerage", directing people
to services is yet another expense to be maintained and will take
money away from the already reducing annual income that is available
for vulnerable people. This is further complicated if league tables
are introduced of performance by providers. There is already disparity
of assessment within Supporting People authorities and this is
amplified across and between different Supporting People authorities
with what is Grade "B" in one authority under the Quality
Assessment Framework may be regarded as an "A" or a
"C" Grade in others. This would skew the view of users
when trying to assess which provider to use.
1.17 Additionally, as some Supporting People
authorities lack resources they have been unable to look at awarding
Grades at the "A" level, even if the provider has self
assessed and in practice merits that level of award. Thus, for
an organisation such as this, this acts as a penalty and may prevent
access to other authorities tendering process as they are looking
for "A" Graded providers.
1.18 Enhancing the Supporting People Directory
of Services: This is of benefit to all users and providers, however,
it is important to ensure that a service, say in Dorset, is given
the same assessment as one in Bromley.
1.19 Enhancing Partnership with the Third Sector
1.20 The Role of the Third Sector: If, as stated,
the Government want to use the Third Sector to provide high quality
and flexible services it should make allowances to pay for the
increasing costs of high quality services. It is expected that
providers work with authorities and users but this is time consuming
and costly so who is paying for this involvement?
1.21 The issue of benchmarking often has a detrimental
impact on service quality. For example, this association has higher
than average overheads as it employs experienced and qualified
staff in general housing, supported housing, finance, human resources,
corporate services, health & safety and information technology
to ensure the association provides high quality support services
to the front line management. Other organisations do not do this.
This organisation also continues involvement with good pension
schemes whilst other organisations pay the minimum. Whilst this
is a commercial issue, never the less who will pick up the long
term impact of smaller pensions when those staff retire?
1.22 Capacity Building: The work of some organisations
such as HACT and Sitra through your funding has proved relevant,
productive, innovative and essential and it is to be congratulated.
It is welcoming to see many Supporting People authorities providing
appropriate training opportunities for providers to access which
is of high quality and meaningful. Unfortunately this can not
be said of all Supporting People authorities and needs to be addressed.
1.23 "Capacity Building" also means
different things to different authorities. Is capacity building
meaning that authorities "put all their eggs in one basket"
in the pursuit of economies of scale to the exclusion of other
providers? So when things go wrong, there is no competition from
other providers and most importantly, little extra help available
for the users requiring support? This action is counter to good
management, flies in the face of advice from Government to local
authorities and local authority representative organisations to
local authorities.
1.24 Building capacity also links into remodelling
existing services and the cost of doing so. This association,
in line with all other good providers, wants to raise its standards
of accommodation but with no guarantee of income matching inflation,
never mind the prospect and challenges of financing 25 year mortgages
with three year contracts, what incentive is this for providers
to be innovative and take risks? How will the Government continue
to encourage authorities to support this expensive and risky process?
1.25 Delivering in the New Local Government Landscape
1.26 Forging new relationships and making the
right links: The prospect of greater integration of services through
partnership working by different organisations is to be welcomed.
However, there are still large gulfs between housing, social care
and health in moving forward. The Government wants service users
to integrate back into the community but it is believed that some
local authorities favour their own accommodation to that of providers
purely from the point of keeping their own services viable at
the expense of other providers who offer high quality non institutionalised
support and surroundings unlike some authority accommodation.
1.27 In Wiltshire, due to funding issues, the
County Council closed down a high quality service for people with
Learning Difficulties who needed the chance to develop after time
in an institutional environment. Why was a project with 5 "A"s
in the Quality Assessment Framework lost when the option taken
was to continue to keep these residents in an institutionalised
environment of the County Council's own project?
1.28 Developing stronger, more effective governance:
Whilst this is to be supported, there is a need to ensure that
this happens in practise. In the Report, section 4.13 states,
"where corporate knowledge and understanding was strong,
Supporting People was a catalyst for wider change and improvement
in cross-functional working". However, Supporting People
in numerous authorities had a role unknown to many within that
authority and had not the support required. As the Supporting
people teams are disbanded, the knowledge and expertise developed
is being diluted and lost, it is difficult to be other than sceptical
of how the introduction of Area Based Grant and Local Area Agreements
will improve local partnerships working and accountability.
1.29 Integrating Supporting People into Local
Area Agreements/developing new PSAs: The comments made in the
previous paragraph apply. Additionally it is necessary to refer
to the importance of two of the National Indicators (NI) used
in Local Area Agreements. These are NI 141 and NI 142.
NI 141 = Number of vulnerable people achieving
independent living
NI 142 = Number of vulnerable people who are
supported to maintain independent living
1.30 From information provided by "Homeless
Link" only 47% (70) authorities used NI 141, and 24% (36)
authorities used NI 142. Over one third of authorities do not
use either of these NIs. Thus the incorporation of Supporting
People funding into Local Area Agreements appears questionable.
1.31 On a positive note if this funding does
allow wider and innovative services to be developed it is to be
welcomed.
1.32 Developing a Supporting People Outcome
Set/Stronger statutory basis for Supporting People/Promoting positive
practice/Funding and Investment: These four headings have been
grouped together as they link a number of themes. Supporting People
have improved standards and promoted good practice which is welcomed.
There are knock on effects to providers of services by way of
training and accommodation cost increases which have not been
matched by increased authority funding nor can be clawed back
by increased rent and charges to users.
1.33 The question to be asked is how can there
be a "stronger statutory basis for Supporting People"
when the ring fencing is being withdrawn and the grant money being
incorporated into a larger pot of money which in turn can be used
for a greater variety of services thinly, if at all, linked to
the present services.
1.34 What has become apparent is that there
is a gradual process of "financial risk shunting" on
to providers as Supporting People limit the number of units they
will finance in their "block capacity" contracts. There
has been no evidence that Supporting People teams will relax this
in the future as they tighten their financial restraints on providers.
Some high profile and high quality providers are considering withdrawing
from the process of regulation by financial harness which would
be a loss to public service due to their innovative thinking and
good practices.
1.35 Linked into the Supporting People national
grant is the issue of Disability Facility Grants (DFG) and the
prospect of incorporating this within the Supporting People regime
is fraught with difficulties for Landlords such as Registered
Social Landlords (RSLs). Firstly RSLs already provide adaptations
to residents and local authorities use RSLs as a separate source
of "income generation" to supplement their over requested
resources. As the DFG grant will be exposed to council tenants
as they become eligible (previously they were ineligible), the
numbers of eligible households will put additional strain on the
available resources. Additionally from an RSC tenants point, tenants
are paying for a mandatory grant several times over in: rent service
charge, council tax, income tax and personal contribution. Will
the Government consider rectifying this inequality?
1.36 Increasing Efficiency and Reducing Bureaucracy:
The new Quality Assessment Framework (QAF) is an improvement on
the previous QAF as far as bureaucracy is concerned. It is more
focussed and links better with the wider remit of Government and
those objectives such as "Sustainable Communities".
1.37 The issue of information provision to Supporting
People authorities remains and is both onerous and costly in its
production but to a large extent is accepted as a necessary requirement.
1.38 In looking to encourage innovation and
comparing costs, I would refer back to earlier comments over quality
of services costing money to ensure those services remain high
quality which service users deserve. The challenge that arises
is where Supporting People authorities decide, unilaterally to
reduce payments to RSLs because their costs are above the average
yet the opposite of increasing payments to these below the average
never seems to occur, or is this kept quiet to avoid other providers,
like Oliver, "asking for more"!
1.39 Additionally, there is bureaucratic pressure
to reduce the number of providers of services in an authority's
area to reduce the administrative burden on Supporting People
teams, but how does this figure in the Government's drive to secure
choice for users?
1.40 The use of improved technology and the
encouragement to develop its use is welcomed where it is appropriate.
It is acknowledged that this thrust also fits in with the Department
of Health's Paper on "Independence, Well Being and Choice"
in 2005, but Anchor's Report "Anchor 2020: Meeting the Challenges
of Older People's Housing and Care" acknowledges that technology
does provide real help to people, "but doesn't replace the
personal contact". This is what is at risk of being over
looked.
2. Consider the implications of the removal
of the ring fence, asking what needs to be done to ensure that
the successes of the programme so far are not lost, or services
cut, following the change
2.1 The implications are potentially substantial,
and need the intervention and support of Government to reduce
the risk of improvements to service users being lost.
2.2 Already this process of service atrophy
has commenced through the disbandment of Supporting People teams
with their various skills and knowledge being subsumed within
different parts of the authority, thus losing its identity. In
losing its identity there will be no champion to represent the
user and provider adequately. The knowledge these teams gained
took a great deal of time to build up, as did their reputation.
Both can be lost very quickly. Thus Supporting People teams need
to be kept as a clear defined separate entity.
2.3 Finance that has supported essential but
non-statutory services will come under increasing pressure to
be used for other purposes, mainly for the statutory services.
There will be a tendency for authorities to quietly transfer money
from the non-statutory services to the statutory services to prop
these up at the expense of essential and good, but not statutory
services.
2.4 Where County and Districts have merged this
year, the local champions and priorities of what were the Districts
have been subsumed into the County priority which are unlikely
to be the same. Thus from an RSL point of view new relationships
will have to be developed, trust gained and adjustments to priorities
made. This will slow down the process of service development.
2.5 There is a need for Government to develop
a system to underpin the requirements of the authorities new inspection
process under the Comprehensive Area Assessment (CAA) but can
be monitored separately to act as a disincentive for authorities
to re-direct the available money originally used for supported
services.
2.6 There is a real danger of "throwing
the baby out of the bath water" as there are many good niche
services which do not meet "the norm". One West County
Supporting People team threatened to withdraw funding from an
Abbeyfield Society project because they were not encouraging independent
living through providing meals for older, now frail residents
and this is what the residents wanted and needed!
2.7 There is a need to ensure that users voices
are not over looked in the authorities drive to focus the finances
on their more favoured services, ie users in accommodation based
services want to retain these such as in sheltered housing but
the authorities want to introduce floating support.
2.8 Whilst there is an obvious move by authorities
to provide floating and peripatetic support, to ensure high quality
staff there should be encouragement to have good terms and conditions
of employment for staff. Users do not like the high staff turnover
and therefore different people they see due to the low wages and
benefits (such as pension arrangements) staff are often given.
2.9 Government should ensure greater priority
and strengthening the resolve of authorities to develop projects
that are difficult such as those for people with substance abuse
or ex-offenders etc.
2.10 To develop such projects requires a substantial
amount of risk and extra work by RSLs which detracts from their
ability to reach their CMA targets. Thus there is a need for Government
to ensure that extra weight is given by the CMA to RSLs in developing
projects which are increasingly difficult to deliver.
2.11 From an RSL perspective, the lenders that
finance association development programmes are becoming more aware
of the vision of risk to revenue funding of projects and are both
trying to increase the rate of interest on finance borrowed and
becoming more reluctant to do so. Hence stability and consistency
of approach is required from the Government to support specialist
developments.
2.12 Partnership working is essential but Health
does not appear to have much inclination to involve themselves
in the supported services area, which is not seen as their core
business. A further suite of appropriate Performance Indicators
(PI) should be developed for Health.
2.13 One of these might be to actively record
how Supporting People monies have been used to finance services
that would have been previously excluded from use under the original
criteria, as well as record what resources such as those from
Health, go into supported housing services and compare what shift
has occurred in resources.
3. Consider what opportunities this change
in the funding mechanism will offer for innovation and improvement
in the delivery of housing related support services.
3.1 Given that the general opinion is that taking
the security of ring fencing away from the Supporting People Grant
is likely to lead to a reduction in services to non-statutory
services it is perhaps very difficult to be fulsome in praise
for opportunities that may arise as a result of this.
3.2 It may serve as a potential catalyst to
obtain revenue funding from other services to bolster service
provision to the benefit of all where it was not possible previously
ie provision of Child Support Workers in Domestic Violence Refuges.
Politically, it may allow staff of the statutory providers extra
freedom as they will have potential support and be working within
the spirit of partnerships required.
3.3 Partnership working should allow a more
holistic approach to service provision covering a greater spectrum
of needs provided under one roof rather than transporting people
to the source of the service. This movement away from the medical
model of service to one of a social model is welcomed.
3.4 This would in particular be able to build
on the existing move to comprehensive service provision in Extra
Care projects which will cover not only people who are frail by
age and disability but also those who develop Alzheimer's Disease
and other dementia illnesses, along with people who can live independently
but with more specific needs such as those with hearing disabilities.
May 2009
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